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In which of the following cases does the burden of proof shift to the IRS?
a. The litigation involves a corporation with a net worth of $12 million.
b. The IRS uses data from the taxpayer rather than statistics to reconstruct an individual's income.
c. The court proceeding against an individual taxpayer involves a penalty or an addition to tax.
d. The partnership involved has a net worth of over $7 million.
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